The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today to disrupt the Islamic State of Iraq and the Levant’s (ISIL) global fundraising and support network by designating four individuals – Neil Christopher Prakash, Khaled Sharrouf, Bachrumsyah Mennor Usman, and Oman Rochman – as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism. Usman was designated for acting for or on behalf of ISIL. He is an ISIL official who commands ISIL fighters, facilitates funding for ISIL operations in Indonesia, recruits for ISIL, and coordinates travel and communications for ISIL members.
Usman had pledged allegiance to ISIL as of mid-2014 and was involved in sending Indonesians to Syria. In early February 2014, Usman claimed he was part of ISIL when he appeared at an event in support of ISIL at a mosque in Indonesia. In September 2014, Usman was identified as the leader of ISIL’s Archipelago Group – also known as Katibah Nusantara – in Syria. He was also designated by ISIL to receive training in bomb-making.
As of March 2016, Usman had transferred $105,000 to the leader of a group of terrorists in Indonesia identified as the “Bekasi cell.” ISIL had ordered that the money be used to carry out attacks in Indonesia. The individual receiving the money had been contemplating attacks in Bali, as well as at an international school and at an airport in Jakarta. As of February 2016, Usman reportedly transferred funds to both Indonesia and the Philippines, and he ordered an associate to plan attacks similar to the January 14, 2016 bomb attacks in Jakarta.
On June 6, 2003, OFAC issued the Global Terrorism Sanctions Regulations, 31 CFR part 594 (68 FR 34196, June 6, 2003 (“the Regulations”), to implement Executive Order (E.O.) 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism” (66 FR 49079, September 25, 2001). OFAC has amended the Regulations on several occasions.
On September 9, 2019, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (IEEPA) and the United Nations Participation Act (22 U.S.C. 287c) (UNPA), issued E.O. 13886, “Modernizing Sanctions To Combat Terrorism” (84 FR 48041, September 12, 2019), effective September 10, 2019. In E.O. 13886, the President, finding it necessary to consolidate and enhance sanctions to combat acts of terrorism and threats of terrorism by foreign terrorists, terminated the national emergency declared in E.O. 12947 of January 23, 1995, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (60 FR 5079, January 25, 1995), and revoked E.O. 12947, as amended by E.O. 13099 of August 20, 1998, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (63 FR 45167, August 25, 1998). In addition, the President amended E.O. 13224, in order to build upon initial steps taken in E.O. 12947, to further strengthen and consolidate sanctions to combat the continuing threat posed by international terrorism, and in order to take additional steps to deal with the national emergency declared in E.O. 13224, with respect to the continuing and immediate threat of grave acts of terrorism and threats of terrorism committed by foreign terrorists, which include acts of terrorism that threaten the Middle East peace process.
Section 1 of E.O. 13886 replaces in its entirety section 1 of E.O. 13224, which had been amended by a number of prior Executive orders (E.O. 13224, as amended by all such authorities, is referred to herein as “amended E.O. 13224”), but does not amend the Annex to E.O. 13224, which was previously amended by E.O. 13268 of July 2, 2002, “Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001” (67 FR 44751, July 3, 2002) (“amended Annex to E.O. 13224”).
